Case Law

In Farmer v Bankers Trust International Ltd 1990 STC 564 the taxpayer lost its claim to modify a claim to group relief, which it had made within the two year limit, subsequent to the expiry of that limit. However, in Gallic Leasing Ltd v Coburn 1991 STC 699 it was held that the claim for group relief was valid even though the amount of the relief was not made available within the two year period. There is no time limit within which the surrendering company had to inform the Revenue of its consent.

A claim for group relief could be made after a company has left the group. AW Chapman Ltd v Hennessy 1982 STC 214